Companies must keep sanctions records for 10 years, not five
What happened
The US Treasury Department now requires companies to keep records related to sanctions for 10 years. This doubles the previous requirement and matches the time the government has to prosecute sanctions violations.
Why it matters
Companies that deal with international trade or finance now have a much longer paper trail to maintain. This means they face a longer period of potential liability if they violate sanctions rules. It also gives the government more time to investigate and prosecute violations.
The signal
Watch for any increase in enforcement actions or penalties related to older sanctions violations, as the government now has more time to pursue them.